BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, DC 20268-0001
RECEIVELI
h]l
11 37A/j’9&
~
POSTAL RAlE COKHISSION
OFFICE OF THli SECrlETARY
Special
Services
Fees
and Classifications)
Docket
No.
‘--*
MC96-3
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES TO UNITED STATES POSTAL SERVICE
WITNESS SUSAN W. NEEDHAM
(OCA/USPS-TB-38-40)
(July
31, 1996)
Pursuant
the
Postal
hereby
Rate
submits
documents.
the
to
United
incorporated
sections
25 and 26 of
Commission,
the
an interrogatory
Instructions
States
Postal
Office
the
of
Rules
the
with
Service
dated
Practice
Consumer
and a request
included
of
for
production
19,
1996,
by reference.
Respectfully
Advoca-ce
OCA Interrogatories
June
submitted,
,&-2J
45Q-Mz
GAIL WILLETTE
Director
Office
of the Consumer
DAVID RUDERMAN
Attorney
Advocate
of
'of
1-4
are
hereby
to
Docket
No.
2
MC96-3
- r-
A comparison
indemnity
fees
for
of
insurance
at
the
Postal
pages
Service's
45-48
of
proposed
your
testimony
a
4
‘A
of
the
i‘iis,urance
fees of competitors
.',
shows that ‘ohe Posta
s.
_'
of the competitors,
\,
$17.15
for RPS and UPS at the $5,000
'1
At page 53 of\ our testimo
x
[insurance]
bear,
fee
customers
delivery
a.
,T..
is
LR-SSR-1
n
alternative
the
Considering
rather
explain
actual
fees
you
t
why customers
insurance
Please
of
level).
statement
explain
4-5
whi
propose.
b.
pages
will
options
Your
at
w
than
what
to
the
use
Postal
:Service
camp
you
"the
price
the
market
can
bear."
OCA/USPS-T&39.
Study
a.
,,..--
Please
Update,
Is
pages
r to
"Time
footnotes)
l?
If
not,
Return
Receipts
Cost
8-9.
the
and
LR-SSR-104,
ibrary
please
Mins."
Reference
provide
the
columns
F-180
source.
from
(both
,main
tables
Docket‘70.
R90i
,
/
/’
/
,/’
\ \
‘1
Docket
, ,--
No.
MC96-3
2
A comparison
OCA/USPS-T8-38.
indemnity
of
the
fees
insurance
shows
that
of
the
v.
$17.15
for
insurance
Please
bear."
not
will
why customers
explain
of
proposed
fees
are
higher
you
seems
than
what
higher
with
the
"so
price
postal
available."
incompatible
with
the
LR-SSR-109
than
(e.g.,
all
$45.70
"abundant"
choose
if
the
the
actual
alternatives,
to
the
market
can
and alternative
currently
would
and
level).
state
abundant
the
testimony
4-5
significantly
the
your
pages
testimony,
are
of
,proposed
at
$5,000
use
Service's
45-48
the
Considering
rather
Postal
pages
consistent
which
statement
explain
/--
is
options
propose.
Service's
your
the
competitors
sometimes
53 of
fee
Your
at
RPS and UPS at
page
delivery
of
Postal
customers
bear,
b.
fees
the
[insurance]
,/--.
insurance
competitors,
At
a.
for
of
use
Postal
fees
you
please
Service
competitors.
you mean by
"the
price
the
market
can
Docket
,-~
b.
No.
What
MC96-3
is
the
procedures
the
C.
3
date
the
a.
Please
b.
return
why it
this
is
or
customers?
to
Can merchandise
so,
At
Mail
from
present,
all
eligible
for
Standard
Mail
explain
why.
Has the
Postal
"merchandise"?
any problems?
If
using
this
to
have
footnote
since
changed.
(1).
at
page
"clearly
this
service.
single
Service
Why or
please
87
exclude
to
with
this
explain.
If
not,
service?
by First-Class
former
except
problems
so,
this
proposing
of
years
service.
encountered
"limit"
you
in
necessary
be sent
why are
the
any
service?
service
need
in
testimony
receipt
Service
its
your
Have
how they
volumes
to
study?
changed
explain
the
Postal
Class
e.
refer
cost
study
so,
Has the
If
d.
Please
from
why do you
C.
for
explain
documents"
If
source
merchandise
original
by the
study?
OCA/USPS-TB-40.
concerning
the
measured
original
Provide
of
Mail
prohibit
under
someone
12 ounces?
using
First
service.
third-class
mail
Your
proposal
piece
from
considered
why not?
excludes
this
publishing
Would
(now Standard)
this
all
Please
service.
a definition
help
is
alleviate
of
r
Docket
No.
MC96-3
CERTIFICATE
I hereby
document
accordance
upon
certify
all
with
that
I have
participants
section
OF SERVICE
3.B(3)
this
of
record
of
the
date
in
served
this
special
DAVID RUDERMAN
Attorney
Washington,
DC
July
31, 1996
,--.
20268-0001
the
foregoing
proceeding
rules
of
in
practice.